IN: Smell of burnt MJ from car allows officer essentially to detain all

Defendant juvenile was a passenger in the back of a car stopped at 1:30 am, and there was a smell of burnt marijuana coming from the car. Under Pringle, that gave the officer cause to get everybody out of the car and potentially arrest them all. K.K. v. State, 2015 Ind. App. LEXIS 473 (June 22, 2015).

A warrantless misdemeanor arrest does not violation the Idaho constitution. Plenty of statutes and case law at the time of statehood already recognized it, and there’s no reason to deviate now. [For those wanting to argue state constitutional rights, there’s a discussion of three cases where violation of a statute was interpreted to create an exclusionary rule, but they had a constitutitonal basis, and this one does not.] State v. Green, 2015 Ida. LEXIS 148 (June 22, 2015).

Defendant was seen coming out of an empty apartment in a NOLA housing project, and that would be trespassing. The stop and search incident were valid. State v. Cavalier, 2015 La. App. LEXIS 1209 (La.App. 4 Cir. June 19, 2015).*